Abstract

Any country undertakes several actions to fulfill the public needs of it’s people or to achieve economical and financial targets. One of the most famous actions are CONTRACTS, the state is usually engaged in several contractual relationships to achieve the aforementioned targets. In both Civil law and Common law systems, the public authorities conclude two types of contracts, the public law contracts and private law contracts. The issue here is what are the criteria in distinguishing the public contracts from private contracts in both Civil and Common legal systems? What are the powers of the public authorities in the Administrative Contracts in both legal systems? To what extent the public law contracts can be considered as bridge between the two systems? These what we will explore together in the following pages. I chose Egypt and France as case study of the Civil law system and USA and UK as case study of the Common law system.

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